Integra Group

1. Sustainable forestry policy or commitment for all its operations?

The company commits to both environmental and social aspects through its sustainability report and good corporate governance.

2. Sustainable forestry policy or commitment applies to all suppliers?

3. High-level position of responsibility for sustainability?

4. One or more members within the board of the company have responsibility for sustainability?

5. Reports gender balance of senior management team?

The company has reported the members of the senior management team. However, no separate figures for men and women were reported.

6. Reports gender balance of board members?

1 - The company has four board members, of which one is female. However, the gender balance of the board members is not directly reported by the company.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with timber and pulp production?

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with timber and pulp production?

The company provides integrated training on Reduced Impact Logging (RIL) activities to its employees in collaboration with The Nature Conservancy, Tropical Forest Fund, and Tropical Forest Foundation to minimise the environmental damage due to illegal logging activity. Additionally, it has partnered with independent organisations such as WWF Indonesia's Global Forest & Trade Network (GFTN) to safeguard the future of the world's forests, protect wildlife, and uphold the livelihoods of local communities.

9. Sustainability report published within last two years?

The company's latest Integrated Annual Report 2023 was published in 2024.

10. Reports through standardised reporting systems?

The company intends to use standardised reporting systems in its upcoming reporting cycle.

11. Climate risks assessment available?

12. Natural capital assessment available?

13. Lists countries and operations?

Indonesia - (forest concessions).

14. Lists countries sourcing from?

The company reports that it mostly sources raw materials from its home country. However, the geographical region is unclear.

15. Total land area managed/controlled for forestry (ha)?

181555 - The company reports its total area managed/controlled for forestry as 181,555 ha.

16. Total area of natural forest designated for wood/wood fibre production (ha)?

163425 - The company reports that it has two forestry concessions namely, PT Narkata Rimba and PT Belayan River Timber with 65,925 ha and 97,500 ha of landbank respectively.

17. Total area of forest plantation (ha)?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

18. Area of plantation/natural forest within outgrower schemes (ha)?

0

19. Unplanted area (areas designated for future development as plantation forest) (ha)?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

20. Conservation set-aside area, including HCV area (ha)?

0

21. Area of Intact Forest Landscape (ha)?

0

22. Number of Forest Management Units (FMUs)?

2 - The company has two FMUs, namely PT Narkata Rimba and PT Belayan River Timber.

23. Maps of forest management units (FMUs)?

The company reports only the coordinates of its FMUs. However, no geo-reference map could be found.

24. Forest management plans available for all FMUs?

Summaries of the forest management plans for PT Narkata Rimba and PT Belayan River Timber are publicly available through FSC reports. However, it does not cover all of the company's operations.

25. Monitoring of forest management plan implementation available?

[Externally verified] The company has published monitoring reports of the forest management plan for its FMUs, PT Narkata Rimba and PT Belayan River Timber. However, it does not cover all of the company's operations.

26. Company has provided valid legal documents to Open Timber Portal on use right (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

27. Company has provided valid legal documents to Open Timber Portal on forest management (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

28. Company has provided valid legal documents to Open Timber Portal on timber harvesting (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

29. Maps of all third-party supplying FMUs?

30. Number of company owned sawmills?

31. Names and locations of company owned sawmills?

32. Number of company-owned pulp and paper mills?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

33. Names and locations of company-owned pulp and paper mills?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

34. Reports total volumes (or percentages) sourced by company-owned sawmills that come from company's own operations and third-parties?

The company reports that approximately 30-50% of timber is sourced from its own forest concessions, while the remaining is sourced from certified suppliers. However, clear figures were not provided.

35. Reports total volumes (or percentages) sourced by company-owned pulp and paper mills that come from company's own operations and third-parties?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

36. Number of third party supplying mills?

37. Names and locations of all third party supplying mills?

38. Reports total volume (or percentages) sourced from third-party supplying mills that come from the supplying mills' own operations and third parties?

39. Procedures to trace raw materials to country of harvest?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria, and it not clear how much supply is covered by the certification.

40. Percentage of supply traceable to country of harvest?

41. Procedures to trace raw materials to FMU level?

Points were awarded based on valid FSC Chain of Custody (CoC) and SVLK certifications.

42. Percentage of supply traceable to FMU level?

43. Time-bound plan for achieving 100% third-party legality verification of FMUs or achieved?

44. Percentage area (ha) verified as being in legal compliance by a third party?

90.01% - The company's 90.01% area is verified as being legally compliant by FSC FM certification.

45. Time-bound plan to source only wood/wood fibre that is in legal compliance verified by a third party?

The company reports that it sources only legal and certified timber for its production. However, it has neither a target nor a specific verification system.

46. Percentage of all wood/wood fibre supply traded/processed verified as being in legal compliance by a third party?

47. Percentage area (ha) FSC FM certified?

90.01% - The company is 90.01% FSC FM certified.

48. Time-bound plan for achieving 100% FSC FM certification of FMUs within 10 years?

49. Percentage of wood/wood fibre supply (tonnes) from all suppliers that comes from FSC FM certified areas?

50. Commitment to source only wood/wood fibre that meets FSC Controlled Wood and/or PEFC Controlled Sources requirements?

The company reports that its wood comes from independently managed forests or FSC-controlled sources. However, it is unclear whether all the wood is sourced from controlled sources.

51. Percentage area (ha) PEFC certified (excluding FSC certified area)?

52. Commitment to zero conversion of natural ecosystems?

53. Commitment to zero conversion of natural ecosystems applies to all suppliers?

54. Commitment to zero deforestation?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

55. Commitment to zero deforestation applies to all suppliers?

56. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). As the policy requirements do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's partial FSC FM or CoC certification.

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion in supplier operations?

58. Evidence of monitoring deforestation and/or ecosystem conversion?

59. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

60. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

61. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

62. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

The company commits to restore forest landscapes after timber harvesting. However, no cut-off date is specified.

63. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

64. Implementing a landscape or jurisdictional level approach?

[Externally verified] Points for external verification have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2 EN). As the Standard does not fully meet the SPOTT indicator criteria limited, externally verified points have therefore been awarded.

65. Biodiversity policy?

The company commits to combat illegal logging that leads to deforestation and protect biodiversity in forest areas affected by its activities and has a biodiversity conservation program. However, it does not report on its policy, targets, or scope.

66. Biodiversity policy applies to all suppliers?

67. Identified species of conservation concern, referencing international or national system of species classification?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that it safeguards some endangered species listed in the Convention of International Trade in Endangered Species of Wild Fauna and Flora (CITES), and follows the convention guidelines on Conservation of Biological Diversity (CBD) and the International Tropical Timber Agreement (ITTA).

68. Examples of species and/or habitat conservation management?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria.

69. Commitment to no hunting or only sustainable hunting of species?

70. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

71. Commitment to protect forest areas from illegal activities?

The company commits to protect forest areas from certain forms of illegal activities, such as illegal logging.

72. Commitment to protect forest areas from illegal activities applies to all suppliers?

73. Evidence of protecting forest areas from illegal activities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria.

74. Commitment to no use of genetically modified organisms?

This indicator is disabled as the company reports that it only sources wood/wood fibre from natural forests.

75. Commitment to no use of genetically modified organisms applies to all suppliers?

76. Commitment to conduct High Conservation Value (HCV) assessments?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

77. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

78. High Conservation Value (HCV) assessments available?

79. High Conservation Value (HCV) management and monitoring plans available?

80. Commitment to the High Carbon Stock (HCS) Approach?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

81. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

82. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since January 2015.

83. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as the company does not produce wood/wood fibre OR only has natural forest operations OR has not undertaken any new planting since April 2015 OR if all new planting has been undertaken since November 2017 and has been covered under combined HCV-HCS assessments.

84. Commitment to conduct social and environmental impact assessments (SEIAs)?

The company makes this commitment through SVLK certification requirements. Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria. The company's FMU (PT Belayan River Timber) reports that it monitors environmental and social impact assessments every semester. However, it does not commit to conduct SEIAs.

85. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

86. Social and environmental impact assessments (SEIAs) available, and associated management and monitoring plans?

87. Company has provided valid legal documents to Open Timber Portal on impact assessments (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

88. Commitment to no planting on peat of any depth?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

89. Commitment to no planting on peat of any depth applies to all suppliers?

90. Landbank or planted area on peat (ha)?

91. Implementation of commitment to no planting on peat of any depth?

92. Commitment to best management practices for soils and peat?

93. Commitment to best management practices for soils and peat applies to all suppliers?

94. Evidence of best management practices for soils and peat?

Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. However, it is unclear if the company has a landbank on peat.

95. Commitment to reduced impact logging?

The company commits to Reduced Impact Logging (RIL) and specifically mentions minimising the impact of logging roads along with other RIL practices.

96. Commitment to reduced impact logging applies to all suppliers?

97. Evidence of implementing reduced impact logging practices?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also reports that it provides training on RIL to its employees in collaboration with The Nature Conservancy, Tropical Forest Fund, and Tropical Forest Foundation.

98. Commitment to zero burning?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

99. Commitment to zero burning applies to all suppliers?

100. Evidence of fire monitoring and management?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that it trains its employees on fire prevention techniques and actively monitors, maintains, and improves its operating efficiency to mitigate the risk of fire in production facilities.

101. Details/number of hotspots/fires in company FMUs?

102. Details/number of hotspots/fires in suppliers operations?

103. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

104. GHG emissions intensity?

105. GHG emissions from land use change in company's own operations (scope 1)?

This indicator is disabled as the company reports that it only has natural-forest based operations OR does not produce wood/wood fibre.

106. GHG emissions from land use change in supplier operations (scope 3)?

107. Progress towards commitment to reduce GHG emissions intensity?

108. Methodology used to calculate GHG emissions?

109. Time-bound commitment to improve water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

110. Water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

111. Progress towards commitment on water use intensity?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

112. Time-bound commitment to improve water quality (BOD or COD)?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

113. Progress towards commitment on water quality (BOD or COD)?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

114. Treatment of pulp and paper mill effluent?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

115. Evidence of sawmill run-off containment and wastewater treatment?

The company reports that it recycles and reuses wastewater before discharging it into waterbodies.

116. Proportion of processing facilities with closed-loop water treatment system?

This indicator is disabled as the company reports that it does not own any pulp or paper mills.

117. Commitment to protect natural waterways through buffer zones?

118. Implementation of commitment to protect natural waterways through buffer zones?

[Externally verified] Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

119. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

The company reports that it does not use chemical fertilisers and pesticides, however, the commitment is unclear and does not cover all operations.

120. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

121. Evidence of eliminating chlorine and chlorine compounds for bleaching?

This indicator is disabled as the company reports that it does not own any pulp or paper mills OR only trades wood/wood fibre.

122. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

123. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

124. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

125. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

126. Chemical usage per ha or list of chemicals used?

The company's FSC report states that no chemicals and pesticides are used in the forestry operations by the FMUs. However, the information is between two and five years old.

127. Implementation of commitment to minimise inorganic fertiliser usage?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC.

128. Integrated Pest Management (IPM) approach?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also reports that it provides training on pest control. However, the information is between two and five years old.

129. Waste management system in place to avoid negative impacts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria. The company also reports that to achieve its zero-waste strategy, its manufacturing division utilises wood waste, including sawdust and bark, as fuel for its kiln dryers. In addition, it has its own waste management facility to deal with industrial waste.

130. Commitment to human rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification. The company also commits to respect human rights, however, it does not refer to the Universal Declaration of Human Rights or its equivalent.

131. Commitment to human rights applies to all suppliers?

132. Progress on human rights commitment ?

133. Commitment to respect Indigenous Peoples' and local communities' rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

134. Commitment to Indigenous Peoples' and local communities' rights applies to all suppliers?

135. Commitment to respect legal and customary land tenure rights?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0) AND SVLK. As the requirements of these certifications do not fully meet the SPOTT indicator criteria partial points have been awarded on the basis of the company's FSC certification and SVLK certification.

136. Commitment to legal and customary land rights applies to all suppliers?

137. Commitment to free, prior and informed consent (FPIC)?

138. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

139. Details of free, prior and informed consent (FPIC) process available?

140. Examples of local stakeholder engagement to prevent conflicts?

[Externally verified] Limited, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements do not fully meet the SPOTT indicator criteria.

141. Details of process for addressing land conflicts available?

The company's FMU PT Narkata Rimba has developed an SOP for conflict resolution with the community. However, no evidence was found that these procedures were developed in consultation with the affected stakeholders.

142. Supports the inclusion of women across forestry operations, including addressing barriers faced?

[Externally verified] The company reports that it is gradually implementing development and training programmes to achieve gender equality and women's empowerment. Its FMU, PT Narkata Rimba also reports that it provides health and safety training to female employees. The information is externally verified, however, it does not cover all operations and is two and five years old.

143. Company has provided valid legal documents to Open Timber Portal on population rights (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

144. Commitment to enable sustainable use of non-timber forest products (NTFPs) by local communities?

145. Commitment to provide essential community services and facilities ?

146. Progress on commitment to provide essential community services and facilities?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also commits to provide essential community services such as scholarships, nutritious food, basic food donations, and periodic free medical services.

147. Commitment to provide business/work opportunities for local communities?

The company commits to provide job opportunities for local communities.

148. Company has provided valid legal documents to Open Timber Portal on labour regulations (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

149. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the FSC Policy for Association (FSC-POL-01-004 V3-0). Full points have therefore been awarded on the basis of the company's FSC certification.

150. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

151. Progress on commitment to respect all workers' rights?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The company also states that it strictly upholds respect for workers' and community rights within the surrounding environment. It reports that it ensures the protection of all employees by maintaining a clean, safe, healthy, and accident-free work environment across its operational areas.

152. Commitment to eliminate gender related discrimination with regards to employment?

The company states that it provides equal opportunities for all employees, regardless of ethnicity, race, or gender, and supports the development of competencies through training and education. However, a clear commitment is not reported.

153. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

154. Progress on commitment to eliminate gender related discrimination with regards to employment?

The company reports that it provides equal opportunities regardless of ethnicity, race, or gender, and supports development through training and education, however, only limited details are provided.

155. Percentage or number of temporary employees?

0 (0%) - The company reports the total number of contract workers for itself and its subsidiaries. However, the data is between two to five years old.

156. Reports gender balance of employees?

346 (22.41%) - The company reports that it has 346 (22.41%) women employees in 2023.

157. Commitment to pay a living wage?

The company reports that it pays wages above the regional minimum wage. However, it does not commit to paying a living wage.

158. Commitment to pay a living wage applies to all suplliers?

159. Progress on commitment to pay a living wage?

160. Reporting of salary by gender?

161. Commitment to address occupational health and safety?

Points were awarded based on valid FSC Chain of Custody (CoC) and SVLK certifications. The company also states that its occupational health and safety standards adhere to the relevant regulations established by the Ministry of Manpower, the Ministry of Health, and the Ministry of Industry. However, it does not refer ILO code of practice on safety and health in forestry work.

162. Commitment to address occupational health and safety applies to all suppliers?

163. Provision of personal protective equipment and related training?

Comprehensive, externally verified points have been awarded on the basis of the company's FSC FM certification (FSC-STD-01-001 V5-2 and FSC-STD-60-004) as the requirements fully meet the SPOTT indicator criteria. Additional points have been awarded according to the percent of company landbank certified by FSC. The FSC audit reports state that the company provides PPE and related training to all of its employees. However, the information is between two and five years old.

164. Time lost due to work-based injuries?

165. Number of fatalities as a result of work-based accidents?

166. Commitment to support smallholders?

167. Programme to support outgrower scheme and/or independent smallholders?

168. Number or percentage of outgrower scheme and/or independent smallholders involved in programme?

169. Process used to prioritise, assess and/or engage non-smallholder suppliers on compliance with company's policy and/or legal requirements?

The company makes this commitment through SVLK certification requirements. As SVLK requirements do not fully meet the SPOTT indicator criteria, partial points have been awarded on the basis of the company's SVLK certification.

170. Number or percentage of non-smallholder suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

171. Suspension or exclusion criteria for suppliers?

The company makes this commitment through the FSC Chain of Custody Certification Standard (FSC-STD-40-004 V3-1). Partial points have been awarded as the requirements do not full meet the SPOTT scoring criteria.

172. Timebound action plans (including Key Performance Indicators) for suppliers to be in compliance with timber and pulp sourcing commitments?

173. Proportion of supply from suppliers that is verified as deforestation and/or conversion-free (DCF)?

174. Commitment to ethical conduct and prohibition of corruption?

The company states that its code of conduct addresses business ethics and corruption. However, it does not explicitly commit to ethical conduct or prohibit corruption.

175. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

176. Progress on commitment to ethical conduct and prohibition of corruption?

177. Company has provided valid legal documents to Open Timber Portal on legal registration (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

178. Disclosure of the company's management approach to tax and payments to governments?

179. Company has provided valid legal documents to Open Timber Portal on taxes, fees and royalties (at the time of SPOTT assessments)?

This indicator is disabled as the company reports that it does not have forest management operations in a country currently covered by Open Timber Portal.

180. Whistleblowing procedure?

The company has a whistleblowing policy and provides details on how whistleblowers are protected. However, it does not specify the steps taken to address the complaints received.

181. Own grievance or complaints system open to all stakeholders?

The company has a social and environmental complaint mechanism in place and provides detailed accounts of the actions taken in response. This is available to both internal and external stakeholders.

182. Details of complaints and grievances disclosed?